SM&CR Conduct Rules Training Requirements

For solo-regulated firms the commencement of SM&CR is fast approaching, and 9th December will be here before we know it. Most firms will have their preparations in full swing by now, whether that is ensuring their senior managers that are in controlled functions will map across to the desired senior manager function, setting up recruitment procedures for senior managers and certification staff or creating a fit and proper assessment to be used at recruitment and annually thereafter. Another piece of the SM&CR puzzle is the requirement to train staff on the conduct rules.

As a reminder (because I am sure you have all been reading our previous articles) the requirements around the conduct rules training are:

1. Senior managers and certification staff must receive training before commencement of SM&CR this year

2. Senior managers must receive an annual refresher

3. All other staff, but excluding ancillary staff, are required to receive training on the conduct rules within one year of commencement, that is by December 2020. Again, annual refresher training is required.

4. Training records, such as a certificate or training log, must be maintained

The FCA are not overly specific about the content of the training, other than the fact it needs to cover the conduct rules appropriate to its audience with the aim of ensuring those individuals understand their obligations. This lends itself to two courses, one for senior managers which covers the individual conduct rules as well as the senior manager conduct rules and a second course for other staff covering the individual conduct rules. Firms are, however, given flexibility as to how they wish to deliver the training. Our opinion is that example-based sessions produce the greatest level of understanding.

At RB Compliance we are excited to announce the release of our two conduct rules e-learning courses:

1. Senior Manager Conduct Rules Training

2. Certification and all other staff Conduct Rules Training

We’ve included a mix of videos, small amounts of text and plenty of scenarios to assist a clear understanding of:

1. The conduct rules themselves

2. An overview of SM&CR

3. How the conduct rules practically apply to a range of organisations / roles

4. Consequences for failing to follow the rules (such as the inclusion on future regulatory references or a finding that the individual is not fit and proper)

If you would like to organise a demonstration of our session simply Contact Us.

Finally, don’t forget that there are other requirements in respect of the conduct rules such as the inclusion of disciplinary action on responses to regulatory reference requests and reporting such instances to the FCA alongside your regulatory reporting.

The pieces of SM&CR are beginning to fall into place.

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